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July 30, 2026
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Citizenship by investment (CBI) lets a person acquire a second nationality in exchange for a qualifying economic contribution, usually a government-fund donation or a real estate purchase. As of July 2026 the five Caribbean programmes start at a harmonised US$200,000, the EU no longer offers a citizenship route after Malta's scheme was struck down, and options like Turkey and Vanuatu round out the global market.
| What it is | Second citizenship in exchange for a qualifying investment |
| Oldest programme | St. Kitts and Nevis, established 1984 |
| Active Caribbean programmes | St. Kitts and Nevis, Antigua and Barbuda, Dominica, Grenada, St. Lucia |
| Caribbean minimum donation | US$200,000 (OECS harmonised floor, from 1 July 2024) |
| Regional regulator | ECCIRA, overseeing the five Caribbean programmes from 2026 |
| Cheapest routes | Sao Tome and Principe and Nauru from about US$90,000; Vanuatu from US$130,000 |
| Fastest processing | Vanuatu, about 1 to 2 months |
| EU citizenship route | None; Malta's scheme was ruled unlawful in April 2025 |
| Typical Caribbean timeline | About 4 to 8 months |
Citizenship by investment is a legal route to a second passport in exchange for a qualifying investment in a country's economy. The two most common options are a non-refundable donation to a government fund and a real estate purchase, though some programmes also accept business investment or government securities. In return, the investor and eligible family members receive citizenship after passing due diligence.
The model began in the Caribbean. St. Kitts and Nevis launched the first enduring programme in 1984, after a short-lived Tonga scheme in 1983, and it became the template that Antigua and Barbuda, Dominica, Grenada, and St. Lucia later followed. Over four decades the industry has professionalised: due diligence is now rigorous, investment options have diversified, and, as of 2026, the Caribbean programmes sit under a single regional regulator.
Two structural shifts define the current market. In the Caribbean, the five OECS states adopted a harmonised US$200,000 minimum donation floor, effective 1 July 2024, and created the Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA) to oversee all five programmes from 2026. ECCIRA standardises biometrics, applicant interviews, annual application caps, and due diligence across the region. This is the most significant Caribbean CBI change in over a decade.
In Europe, the direction is the opposite. On 29 April 2025 the Court of Justice of the EU ruled in Case C-181/23 that Malta's citizenship-by-investment scheme was unlawful, holding that EU nationality cannot be granted as a commercial transaction. Malta was the last EU member state operating such a programme, so there is currently no route to EU citizenship purely through investment. Several EU states still offer residency by investment, but residency is a different status.
The core benefits are mobility, security, and optionality for a family. A second passport widens visa-free travel, provides a contingency if a home country becomes unstable, and can open access to banking, education, and business networks in new regions. These are structural advantages of holding a second nationality, not guarantees tied to any single programme.
The five Caribbean programmes are the most established and popular routes, especially for applicants who want speed and no residency requirement. Since the 2024 harmonisation they share a US$200,000 donation floor, so the differences now lie in real estate minimums, passport strength, family rules, and features like Grenada's E-2 treaty. The table compares them on the dimensions that matter most.
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| Programme | Min. donation (single) | Real estate route | Est. | Notable feature |
|---|---|---|---|---|
| Dominica | US$200,000 | From US$200,000 (3-year hold) | 1993 | Lowest entry point; publishes an official processing estimate |
| Antigua and Barbuda | US$230,000 | From US$300,000 | 2013 | University fund route can favour large families; 5-day residency in first 5 years |
| Grenada | US$235,000 | From US$270,000 | 2013 | Only Caribbean programme with a US E-2 treaty |
| St. Lucia | US$240,000 | From US$300,000 | 2015 | Government bond route also available |
| St. Kitts and Nevis | US$250,000 | From US$325,000 (7-year hold) | 1984 | Oldest programme; strongest passport in the group |
Dominica offers the lowest entry point and a published processing estimate. St. Kitts and Nevis holds the strongest passport in the group and the longest track record. Grenada is the only one with a US E-2 treaty, which lets its citizens apply for a US investor visa after meeting domicile requirements. Antigua and Barbuda can favour large families through its university fund route, and St. Lucia adds a government bond option. For a fuller side-by-side, see the guide to the Caribbean passport by investment.
There is no longer a citizenship-by-investment route inside the European Union. Malta ran the last one, and the ECJ ended it in April 2025. Future access to Maltese nationality is being redirected toward a merit-based framework that rewards genuine contribution rather than payment, so it is not a buy-in programme.
Austria is often listed as a European option, but it does not operate a standard CBI programme. Its citizenship law allows discretionary naturalisation under Article 10(6) for a person who makes an exceptional contribution to the country, assessed case by case with no published price. It is rare, opaque, and not a reliable purchase route. Investors who want a European base now generally look to residency-by-investment programmes such as the Portugal Golden Visa, which can lead to citizenship over time through naturalisation rather than direct purchase.
Several countries in the Middle East, Asia, and the Pacific run active programmes with very different economics. Turkey is the largest by volume, Vanuatu is the fastest, and Jordan sits at the higher end. The table sets out the main non-Caribbean routes and their current status.
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| Programme | Minimum investment | Route type | Indicative timeline | Status note |
|---|---|---|---|---|
| Turkey | From US$400,000 | Real estate (3-year hold) or US$500,000 other assets | 6 to 12 months | Open; no Schengen visa-free access |
| Egypt | From US$250,000 | Real estate, deposit, or fund contribution | About 8 months | Open; limited passport mobility |
| Jordan | From US$750,000 | Job-creating projects, bonds, or company shares | About 3 months | Open; capped at 500 approvals per year |
| Vanuatu | From US$130,000 | Development Support Programme donation | 1 to 2 months | Open; fastest route, weaker passport |
| Malta | Closed | Former direct-investment naturalisation | Not applicable | Ended after the ECJ ruling of 29 April 2025 |
| Austria | No set price | Discretionary naturalisation for exceptional contribution | Case by case | Not a standard buy-in CBI programme |
Turkey offers a recoverable real estate route from US$400,000 and a fast timeline, though its passport does not include Schengen access. Vanuatu is the quickest at one to two months but carries a weaker passport. Egypt and Jordan serve investors focused on regional access rather than global mobility. Each suits a specific goal, so the right choice depends on why you want the second passport.
Start from the goal, not the price. Mobility, family inclusion, speed, US access, and cost each point to a different programme, and the cheapest option is rarely the best fit once the goal is clear.
The recurring errors are chasing the lowest headline price, relying on outdated figures, and misreading residency as citizenship. The market has changed fast, and old guides mislead.
Sergey Voinich, Founder and Managing Partner at Golden Harbors, notes: "The clients who choose well start from what they actually need the passport to do, mobility, a US path, a family plan, and let that pick the programme. Starting from the sticker price is how people end up with the wrong citizenship."
Citizenship by investment is a legal route to a second nationality in exchange for a qualifying economic contribution, usually a government-fund donation or a real estate purchase. The investor and eligible family members receive citizenship and a passport after passing due diligence. Programmes are run under national law, and the Caribbean ones now sit under a shared regional regulator.
Costs vary widely as of July 2026. The cheapest routes are Sao Tome and Principe and Nauru at about US$90,000 and Vanuatu at US$130,000. The five Caribbean programmes start at US$200,000 under the OECS floor. Turkey starts at US$400,000 and Jordan at US$750,000. Government, due diligence, and legal fees are additional to these base amounts.
No. The Court of Justice of the EU ruled Malta's scheme unlawful on 29 April 2025, ending the last EU citizenship-by-investment route. There is currently no way to obtain EU citizenship purely through investment. Several EU states still offer residency by investment, but residency does not grant an EU passport directly and follows a separate, longer path.
Dominica has the lowest entry point among the five Caribbean programmes at a US$200,000 donation, exactly on the OECS harmonised floor. Antigua and Barbuda follows at US$230,000, Grenada at US$235,000, St. Lucia at US$240,000, and St. Kitts and Nevis at US$250,000. Real estate routes cost more upfront and carry holding periods.
Timelines depend on the programme. Vanuatu is fastest at about one to two months. The Caribbean programmes generally take four to eight months, with Dominica citing roughly three to four. Turkey runs six to twelve months and Egypt about eight. Due diligence and the completeness of the source-of-funds file affect every timeline more than any advertised figure.
Grenada is the only Caribbean citizenship-by-investment country with a US E-2 investor treaty. After meeting domicile requirements, Grenadian citizens can apply for the E-2 non-immigrant visa to invest in and run a US business. No other Caribbean programme offers this. The E-2 is not a green card, but it can be renewed while the US business operates.
Most citizenship-by-investment programmes impose no ongoing residency requirement, and the citizenship is generally for life and passable to children. Some programmes add limited in-person steps, such as Antigua's five-day visit within the first five years, or biometric enrolment under the new Caribbean rules. Confirm the specific in-person and biometric obligations for the programme you choose.
For most people, tax depends on where they are resident and domiciled, not on citizenship alone, so a second passport is not by itself a tax strategy. Some CBI countries, such as St. Kitts and Nevis, levy no personal income tax on worldwide income. US citizens remain taxed on worldwide income regardless of a second passport. Always confirm with a qualified tax adviser.
Golden Harbors advises entrepreneurs, family offices, and internationally mobile families choosing among citizenship-by-investment programmes. The team starts from the goal, whether that is a stronger passport, a US business path, a family plan, or a fast timeline, and matches it to the right programme rather than the lowest headline price. Advisors handle source-of-funds documentation, coordinate with authorised agents, and keep every figure current against the official government units, which matters more than ever under the new ECCIRA rules. To go deeper on specific routes, see the guides to the Caribbean passport and Grenada citizenship by investment.
Ready to move from research to action? Book a general consultation call with Golden Harbors, global mobility experts who walk you through the right citizenship-by-investment programme, investment route, timeline, and trade-offs for your specific situation.
Book a CallAbout the Author
Sergey Voinich, Founder and Managing Partner at Golden Harbors, is a foreign attorney specializing in international, patent, and copyright law, with over 20 years of experience across CIS finance and US technology sectors. He has held roles at PayPal, eBay, and Amazon and is certified by the Investment Migration Council. At Golden Harbors, he leads a team focused on global citizenship and residency solutions for entrepreneurs and family offices.
Last reviewed: July 2026.
Disclaimer: This article is for informational purposes only and does not constitute legal, tax, or immigration advice. Program terms, tax rates, and regulatory requirements change frequently. Verify current requirements before acting.
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Victoria
Lead Attorney at Golden Harbors